Arkansas Code Annotated

Ark. Code Ann. § 17-81-102 (2026)

Definitions

✓ current as of May 2026
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As used in this chapter:

  1. “Analysis” includes physical examination, the use of X-ray and other analytical instruments, and procedures generally used in the practice of chiropractic;
  2. “Board” means the Arkansas State Board of Chiropractic Examiners;
  3. “Chiropractic” means that science and art which utilizes the inherent recuperative powers of the body and deals with the relationship between the nervous system and the spinal column, including its immediate articulations, and the role of its relationship in the restoration and maintenance of health;
  4. “Chiropractic aide” means an unlicensed member of the chiropractic team who may assist a chiropractic physician in the performance of those procedures and techniques constituting the practice of chiropractic as defined in this chapter with the exception of spinal manipulation and adjustment, provided that such assistance shall be performed under the direct supervision of a licensed chiropractic physician;
  5. “Physician” means a person authorized or licensed to practice medicine pursuant to the Arkansas Medical Practices Act, § 17-95-201 et seq., § 17-95-301 et seq., and § 17-95-401 et seq., a person authorized or licensed to practice chiropractic pursuant to the provisions of this chapter, and a person authorized to practice osteopathy pursuant to § 17-91-101 et seq.;
    1. “Practice of chiropractic” means the engagement in the diagnosis and analysis of any interference with normal nerve transmission and expression, and the procedure preparatory to and complementary to the correction thereof by an adjustment of the articulations of the vertebral column, its immediate articulations, including spinal adjustments, spinal manipulations, and spinal mobilizations, such as any type of pressure, force, thrust, or passive movement, singular or plural, applied to the spinal vertebrae or their adjacent articulations by hand or mechanical device or by other incidental adjustments, for the restoration and maintenance of health. The practice of chiropractic includes therapy, the normal regimen, and rehabilitation of the patient for the purpose of removing any injury, deformity, or abnormality of human beings without the use of drugs or surgery.
    2. The practice of chiropractic, as authorized under the provisions of this chapter, shall not include the performance of the duties of a midwife or obstetrician, therapy by the use of ionizing radiation, incisive surgery, prescribing for or administering to any person any drug to be taken internally, or puncturing the skin for the purpose of introducing any substance into the body. Nothing herein shall prevent puncturing the skin for routine blood analysis, including red blood count, white blood count, differential and serology, in the practice of chiropractic for diagnostic purposes; and
  6. “Spinal manipulation” and “adjustment” mean the skillful or dexterous treatment whereby a corrective force or passive movement of the joint is made to realign vertebrae or articulations to their normal juxtaposition.

History. Acts 1971, No. 706, §§ 3, 17; 1975, No. 612, § 1; 1981, No. 568, § 1; 1983, No. 148, § 1; A.S.A. 1947, §§ 72-417, 72-431, 72-434; Acts 1987, No. 354, § 1; 1999, No. 1553, § 1.

Case Notes

Expert Witness.

A chiropractor is competent to testify in a personal injury action, as an expert medical witness, concerning matters within the scope of the profession and the practice of chiropractic. Hardy v. Bates, 291 Ark. 606, 727 S.W.2d 373 (1987).

In a slip and fall case, pursuant to Fed. R. Evid. 702, the trial court did not abuse its discretion in admitting the chiropractor's opinion regarding causation as reliable because: (1) he based his opinion on his education, training, and proper chiropractic methodology and reasoning in treating the injured party and forming an expert opinion; (2) he relied on accepted chiropractic tests and took a thorough patient history from the injured party; (3) he did not base his conclusions solely on the injured party's statements, but, instead, used his many years of experience and training to treat her condition and provide treatment; (4) he did not deviate in any way from his normal practice of conducting chiropractic examinations; and (5) he qualified as an expert in chiropractic treatment under subdivision (6) of this section. Kudabeck v. Kroger Co., 338 F.3d 856 (8th Cir. 2003).

Illegal Practice of Chiropractic.

Evidence supported the Arkansas State Board of Chiropractic Examiners' finding that physical therapist's treatments, which caused his patients' spines to “pop,” were “spinal manipulations” as defined in this section and could only be performed by licensed chiropractors. Teston v. Ark. State Bd. of Chiropractic Examiners, 361 Ark. 300, 206 S.W.3d 796, cert. denied, 546 U.S. 960, 126 S. Ct. 480, 163 L. Ed. 2d 363 (2005).

Illegal Practice of Medicine.

Chiropractors who indicated that they could perform numerous treatments and diagnostic functions in addition to various therapies were engaged in the illegal practice of medicine. Kuhl v. Ark. State Bd. of Chiropractic Exmrs., 236 Ark. 58, 364 S.W.2d 790 (1963) (decision under prior law).

Notes of Decisions
Cited in 5 cases, 2003–2020 · leading case: Teston v. Arkansas State Bd. of Chiropractic Examiners, 206 S.W.3d 796 (Ark. 2005).
Teston v. Arkansas State Bd. of Chiropractic Examiners, 206 S.W.3d 796 (Ark. 2005). · cites it 3× “” Ark. Code Ann. § 17-81-102 (7) (Repl. 2002).”
Dollar Gen. Corp.; Dolgencorp, LLC, D/B/A Dollar Gen.; Caddo Trading Co., Inc.; & Rodney Fagan & Judy Fagan v. Karen Elder, 2020 Ark. 208 (Ark. 2020). · cites it 2× “” Ark. Code Ann. § 17-81-102 (5) (Repl. 2018).”
Dollar Gen. Corp. Dolgencorp, LLC, d/b/a Dollar Gen. Caddo Trading Co., Inc. & Rodney Fagan & Judy Fagan v. Karen Elder, 2020 Ark. 208 (Ark. 2020). · cites it 2× “” Ark. Code Ann. § 17-81-102 (5) (Repl. 2018).”
Teston v. Ark. State Bd. of Chirop. Exam., 206 S.W.3d 796 (Ark. 2005). · cites it 3× “" Ark.Code Ann. § 17-81-102(7) (Repl.2002).”
Donna Kudabeck v. The Kroger Co. (8th Cir. 2003). “Ark. Code Ann. § 17-81-102 (6) (Michie 2002) (Arkansas Chiropractic Practices Act).”
— Ark. Code Ann. § 17-81-102(7) — 2 cases
Teston v. Arkansas State Bd. of Chiropractic Examiners, 206 S.W.3d 796 (Ark. 2005). “” Ark. Code Ann. § 17-81-102 (7) (Repl. 2002).”
Teston v. Ark. State Bd. of Chirop. Exam., 206 S.W.3d 796 (Ark. 2005). “" Ark.Code Ann. § 17-81-102(7) (Repl.2002).”
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